Affordable Care Act and Benefits Compliance Part 3: ACA Reporting

For the third part of our ACA refresher series, let’s take a look at what reporting is required of the Affordable Care Act so you can make sure you’re compliant. (And if you’d like additional background, here are parts 1 and 2 of our benefits compliance refresher.)

What Reporting Does ACA Require?

The employer (and in some cases, the insurer) is required to include information about who is covered by the Affordable Care Act, who is offered coverage, who took the coverage and how much the coverage was. This information is found on the 1094 and 1095 forms.  

1095 forms are due to employees on January 31 of the following year (January 31, 2022 for the 2021 calendar year). 1094 forms are due to the IRS by the following February 28 if submitted in paper form, or by March 31 if filed electronically. 

Each year the IRS has extended the deadline to provide 1095 forms to employees by 30 days, but this year, we do not anticipate this extension for 2021 filing, so it’s important to ensure your employees receive their 1095 forms by January 31, 2021. 

Part 1 on the 1095-C form is about the employee; part 2 is mostly where the information for the ACA required reporting will be. Part 3 asks the employer to complete a list of covered individuals and which months they were enrolled in the plan. Depending on what plan you offer and what the size of your company is will determine what type of reporting and information is required. 


If you file more than 250 W-2s in the previous calendar year, you are required to report the total cost of the employee’s health insurance for employer-sponsored health coverage. You must include employee and employer contributions even though it is non-taxable. This is optional for employers who filed fewer than 250 W-2s in the previous calendar year.

Changes to ACA’s Electronic Filing Process

The IRS has proposed two significant changes to the electronic filing process. The proposed changes would also affect the filing of W-2 and 1099. 

The ACA filing threshold for e-filing will be reduced from 250 returns to 100 for returns due in 2022 (and to 10 for returns due in 2023). 

Additionally, employers would be required to aggregate the number of different returns it files when determining whether the 250-return threshold is reached. 

For example, the employer would aggregate all W-2s, forms 1095-C and forms 1094-C to determine a total amount. If that amount surpasses 100, the forms must be transmitted and filed electronically. If this proposal goes into effect, this rule will result in almost all employers electronically filing for 2023.

How Cornerstone Can Help With ACA

We know you’re busy, and staying compliant with the ever-changing (and often complex) ACA rules can be difficult. By working with AssuredPartners Cornerstone, you can be assured that your workplace — and employees — are covered and compliant.

Connect with our human resources experts if you’d like assistance with the benefits administration process. Our skilled team can ensure you offer a healthcare plan for your employees that is ACA compliant.   

If you have any questions or concerns about the Affordable Care Act and how it affects you or your employees, contact Cornerstone today.